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performed in the United States and is treated entirely as income
from sources within the United States. Sec. 861(a)(3).
(6) Treasury Bills, Wires and Checks,
Gold and Silver Futures, Project
Income, Income from Investments,
Other Commission Income, Other
Commissions and Fees,
and Other Income
Petitioners do not specifically address either the character
or the source of such income items. Consequently, we treat
petitioners as having conceded such items. Accordingly, we
sustain respondent's determinations that the income in each such
category is characterized as compensation for personal services
income performed in the United States and is treated as income
from sources within the United States. Sec. 861(a)(3).
3. Effectively Connected Income Rules
a. Introduction to the Rules
A foreign corporation engaged in trade or business within
the United States is taxed on income which is "effectively
connected with the conduct of a trade or business within the
United States" (hereinafter effectively connected). Sec.
882(a)(1). For this purpose, income from sources within the
United States generally is segregated between two categories,
pursuant to section 864(c)(2) and (3). The income to which
section 864(c)(2) applies includes, inter alia, income described
in section 871(a)(1), section 871(h), section 881(a), or section
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